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Parties Disagree on Suitability of FirstNet Interoperability Matrix

The First Responder Network Authority (FirstNet) and AT&T, Inc., FirstNet’s network partner, are urging the FCC to endorse FirstNet’s interoperability compliance matrix. But other parties are raising some concerns about it, or at least that the FCC’s review of alternative state plans will overlap with that of the National Telecommunications and Information Administration (NTIA).

An order adopted last month setting procedures for Commission review of alternative state FirstNet plans instructed the Public Safety and Homeland Security Bureau to seek comments on the matrix in an expedited fashion (TR Daily, June 22 and 23).

Congress has charged the FCC with reviewing whether alternative state plans would comply with minimum technical interoperability requirements. If the FCC approves a state plan, the state has to apply to NTIA for authority to secure a spectrum capacity lease agreement with FirstNet. States seeking to build their own radio access networks (RANs) may also apply to NTIA for grant funds to help cover those costs. In reviewing alternative plans, NTIA will seek to ensure that states make five technical and financial demonstrations.

“The Middle Class Tax Relief and Job Creation Act of 2012 (the ‘Act’) [the relevant portions of which are also known as the Spectrum Act] requires FirstNet to ‘develop…the technical and operational requirements of the network [and] practices, procedures, and standards for the management and operation of such network.’ Toward that end, on June 16, 2017, FirstNet submitted to the Federal Communications Commission (‘Commission’ or ‘FCC’) only the network policies that will be relevant to the Commission’s interoperability determination,” FirstNet said in its comments in PS docket 16-269. “FirstNet put considerable effort into creating its network policies, which have been informed by public safety stakeholder input and FirstNet collaboration with its nationwide public safety broadband network (‘NPSBN’) partner, AT&T.”

FirstNet noted that under the law, “the FCC is responsible for either approving or disapproving an alternative plan based on whether the state or territory has demonstrated that it will be (1) in compliance with the minimum technical interoperability requirements contained in the Interoperability Board Report (‘Prong 1’), and (2) interoperable with the NPSBN (‘Prong 2’). The Act tasked FirstNet with establishing the network policies for the NPSBN, including policies related to technical and operational requirements of the NPSBN. Thus, FirstNet is responsible for providing the FCC with the technical and operational requirements necessary to ensure that an opt-out State’s alternative plan will be ‘interoperable with the NPSBN’ under Prong 2. As noted above, to satisfy its statutory responsibility, FirstNet submitted the interoperability requirements for the NPSBN to the FCC for the Commission’s use in evaluating alternative plans. In so doing, FirstNet identified two additional requirements beyond the Prong 1 requirements that were adopted by the Commission in its Report and Order. These two requirements were included as requirements (‘SHALLS’) [4]-[5] in the Interoperability Board Report.”

FirstNet added that it “identified the two additional requirements to highlight the need for an opt-out State’s Radio Access Network (‘RAN’) to be able to support multiple Access Point Names (‘APNs’) in order to ensure both interoperability and public safety custom usage. The FirstNet solution incorporates the use of general, specific, and custom APNs. While APN interoperability is primarily between the User Equipment (‘UE’) and the Core Network, support of multiple APNs in a device will also require the device to interoperate with the RAN in order to set up multiple default and dedicated bearers based on supported APNs. Accordingly, FirstNet included these two requirements in the revised interoperability compliance matrix as part of the Prong 2 requirements that will be necessary to ensure interoperability with the NPSBN.”

In its comments, AT&T said that “the Commission must adopt and apply – as is – the interoperability compliance matrix submitted by FirstNet on June 16, 2017. Moreover, the Commission must not otherwise attempt to second-guess what FirstNet believes are network policies necessary for successful opt-out state integration.”

“The Commission has ‘stated its view that the statute calls for the Commission to independently and impartially evaluate whether alternative plans comply with the interoperability-related requirements established by FirstNet, but does not empower the Commission to impose network polices or interoperability requirements on FirstNet,’” AT&T noted. “The Commission’s view of the statute is correct: FirstNet – and FirstNet alone – establishes the interoperability requirements; and then the Commission determines whether any alternative plan submitted for review by any opt-out state complies with FirstNet’s interoperability requirements.”

Cellular South, Inc. d/b/a C Spire Wireless, Inc., said “the proposed FirstNet matrix requirements listed under the column labeled ‘FCC Evaluation Requirements’ are based on applicable, established 3GPP and other standards for designing an interoperable LTE network. These requirements provide a useful and relevant set of criteria for determining interoperability, and for providing a meaningful opportunity for states to opt-out.”

But C Spire complained that FirstNet’s interoperability matrix filing “also makes general statements about potentially enabling NTIA to apply a completely separate interoperability analysis after the Commission completes its own review. FirstNet suggests that NTIA’s review may incorporate criteria included in either version of its Interoperability Matrix, as well as other requirements outside of these matrices. This is contrary to the Act, which unambiguously reserves the substantive decision on interoperability solely to the Commission. The Act provides no authority for NTIA to perform its own parallel interoperability review. Instead, the Commission is charged with reviewing state plans to ensure that they are consistent with the minimum technical requirements and that they are ‘interoperab[le] with the nationwide public safety broadband network.’”

C Spire also argued that “[n]othing in the Act or the Matrix requirements prohibits opt-out states from interconnecting a state-run core with the FirstNet national core. For example, if Mississippi decided that it needed to provide higher priority to public safety users via more aggressive preemption of non-public-safety traffic, it could not do so by deploying a state-specific RAN alone. It would require access to and control of a state-specific core. Indeed, Congress would not have created a specific opt-out process if all it intended to do was allow states to run dumb pipes without any local input into technology or capabilities.”

However, FirstNet has said that states must use FirstNet’s core to provide public safety services, and AT&T concurs.

The Competitive Carriers Association said “it is critical that the opt-out process follow three important tenets: (1) the review process must be realistic and attainable; (2) evaluation must flexibly embrace different network configurations including core-to-core interconnection; and (3) the NPSBN’s design should ensure that handsets used in the FirstNet ecosystem include all LTE bands, not just those chosen by AT&T.”

“If a state desires to opt out, the FCC, NTIA, and FirstNet should review its proposal with deference, and presume that its alternative plan will promote public safety within that state and for the NPSBN,” CCA argued. “The Spectrum Act’s opt-out provisions make clear that Congress agrees with this assessment, and provides a clear pathway for states that require local network control. It is essential that the Commission, NTIA, and FirstNet ensure that the opt-out process remains a viable option. To that end, CCA urges the FCC to remove unnecessary burdens to core-to-core interoperability, and ensure that any minimal requirements imposed on states are truly essential to the reliability and performance of the network. Unfortunately, FirstNet’s Matrix threatens this careful balance by imposing opaque layers of technical restrictions on states’ ability to opt-out. Instead, the statutory design requires FirstNet to adopt network policies consistent with the minimal technical requirements developed by the TAB [FCC Technical Advisory Board].”

“FirstNet’s submission to the Commission sends mixed messages,” said Rivada Networks LLC, which led a consortium that lost out to AT&T for the FirstNet contract. The current, June 16 version of FirstNet’s interoperability matrix appears to require only that alternative state plans embrace well tested and well understood industry standards. They therefore would provide a reasonable set of requirements for the Commission to apply in its interoperability review, without going beyond what is necessary to ensure an interoperable, reliable, and secure public responder network. The Commission should make clear that it will apply these — and only these — criteria in its interoperability review of state alternative plans.

“However, FirstNet suggests that it and NTIA may also impose new, unexplained, and possibly unjustified criteria in the course of their own interoperability review,” Rivada added. “This duplicative step would be neither warranted nor permitted under the Spectrum Act. Moreover, such a review, and the uncertainty it may create, will only serve to frustrate states’ efforts to serve the needs of their first responders and the public they protect.”

“FirstNet’s spreadsheet of technical standards is ambiguous,” said Southern Linc. “The standards referenced in FirstNet’s spreadsheet incorporate numerous potentially incompatible options; however, FirstNet never identifies – much less explains – which of the options states should choose or which of the options FirstNet itself intends to follow. Worse, FirstNet’s ambiguous references could offer states the appearance of flexibility when in reality any option within a standard that a state chooses to complete its network design will turn out to have been the ‘wrong’ one in FirstNet’s subsequent estimation.”

“The spreadsheet also omits standards states will eventually need to know to interconnect with the FirstNet system,” Southern Linc added. “For instance, in a roaming arrangement, should state opt-out designs support local breakout or home-based-routing? States do not need to know which of these options FirstNet prefers to design their state networks, but states will eventually need to know this information to interconnect with FirstNet’s system. FirstNet’s omission of these and similar standards and protocols governing connectivity make the agency’s spreadsheet an unreliable tool for the Commission to use in conducting its interoperability review under the Spectrum Act. The type of reference material FirstNet has submitted to the Commission could help identify shortcomings in interoperability and assist opt-out states in network design and implementation. But the one-page spreadsheet FirstNet has submitted in this proceeding falls short of that goal. Rather than guide states toward achieving the shared goal of an interoperable network, FirstNet offers a vague, uneven collection of references that will frustrate rather than promote public safety interoperability.”

“The revisions requested by FirstNet should be rejected by the Commission because they violate the Spectrum Act by shifting the Commission’s statutorily mandated responsibility for evaluating technical operability of alternative RANs to the NTIA,” said the FirstNet Colorado Governing Body. “In addition, the revisions create additional interoperability parameters which should be rejected, including compliance with FirstNet’s yet to be seen Network Policies. In all cases, the roles of the Commission and the NTIA in reviewing interoperability are distinct. Contrary to FirstNet’s suggestion, the Commission must ensure that there is no overlap in review. Finally, in order to ensure equal standing between opt-states and FirstNet, the Commission must evaluate the AT&T national plan for compliance with the minimum interoperability requirements.”

America’s Public Television Stations (APTS) submitted comments “to discuss the critical role that public television stations can play in the FirstNet public safety network. Although these comments do not directly address the Federal Communications Commission’s (‘Commission’) proposed parameters and timelines for the states that opt-out of FirstNet, APTS believes these comments will be helpful to the Commission’s record in this proceeding. Public television is capable of leveraging its nationwide network of high-power broadcast television stations in conjunction with digital datacasting to create a nationwide wireless IP delivery network that is natively one-to-many, in order to improve first responder access to critical information during emergencies. In this way, public television may serve as a complementary system with the FirstNet LTE network.”- Paul Kirby, paul.kirby@wolterskluwer.com